Giving Compass' Take:

• This issue brief provides background information on Russia-Ukraine sanctions and recommendations for donors on how to best support civil society efforts in the region. 

• How do you incorporate civil society efforts into your giving strategy? 

• Learn more about the Ukraine Crisis Relief Fund.


In response to the Russian invasion of Ukraine, the international community has imposed severe and unprecedented economic sanctions on Russia and certain regions of Ukraine. Some of these sanctions raise concerns for civil society organizations operating in Russia and Ukraine, and for donors working to support them.

The scope of the sanctions in the Russia-Ukraine context are sweeping. While the situation is dynamic and fluid, we urge donors to be confident in their mission and intent. President Biden, in announcing the sanctions, made clear that humanitarian efforts were to be supported and protected. Additionally, there are steps that donors can take to ensure their compliance with sanctions.

In partnership with the Charities Aid Foundation (CAF) America, which works to facilitate regulatory compliant grants to organizations operating in regulated contexts, the Charity & Security Network (C&SN) co-produced When the Giving Gets Tough: Navigating Risk in Sanctioned Locations, a report with recommendations for donors aiming to support groups in sanctioned contexts. The report recommendations apply to donors working to address the crisis in Ukraine and to support civil society operations in both Ukraine and Russia. They include:

  • Implementing a risk-based approach
  • Documenting your due diligence process
  • Understanding your bank’s policies on fund transfers to high-risk countries
  • Working with an intermediary grantmaker
  • Identifying alternative grantees

CAF America has also published a list of organizations providing aid to Ukrainians that donors can support, as has the UK-based Charities Aid Foundation.

Likewise, in their Development Assistance and Approaches to Risk in Fragile and Conflict-Affected States report, the Organisation for Economic Co-operation and Development (OECD) makes a number of recommendations for donors operating in challenging environments, including:

  • Donors need to ensure that their understanding of risk is in fact grounded in ‘country realities.’ Where they understand the operating context, donors feel more comfortable taking and managing risks.
  • It is important to get the balance right between the different types of risk, and to understand the interaction between mitigation measures.
  • Donors need to be aware that they are not the only players in the risk environment, which is generally comprised of a complex political economy, involving competing agendas, interests and perspectives among local (and even regional) stakeholders.
  • Flexibility is essential to successful risk management…donors need the capacity and flexibility to adapt their risk frameworks and their programme design to changing conditions on the ground.